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AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT

2018/19

MODERN AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT FOREWORD FROM OUR CEO PG2

AT DR. MARTENS, WE BELIEVE IN INTEGRITY.integrity. DURING THE PAST YEAR WE: WE ARE FAIR,fair, WE DO THINGS THE RIGHT WAY, + Updated our policies to strengthen our + Expanded our modern slavery training to key AND WE DO NOT CUT CORNERS. THESE VALUES expectations from our employees and suppliers in our supply chain values our suppliers MEAN WE DO NOT ACCEPT MODERN SLAVERY + Became signatory of Better Retail Better IN ANY FORM. NO ONE SHOULD BE FORCED TO + Established a confidential employee hotline World, an initiative supporting global efforts WORK AGAINST THEIR WILL OR HAVE TO PAY to achieve the UN Sustainable Goals + Extended our CSR audits to the lower tiers of FOR A JOB, BUT TODAY MILLIONS OF PEOPLE our supply chain GLOBALLY ARE VICTIMS OF MODERN SLAVERY. AS A BUSINESS, WE ARE committedCOMMITTED TO NEXT YEAR, WE WILL CONTINUE TO: RESPECTING HUMAN RIGHTS AND IDENTIFYING, + Map risks in our supply chain and + Collaborate further with others in INVESTIGATING, ENGAGING AND REMEDIATING own operations the industry ANY ISSUES UNCOVERED. + Provide more training to our own employees

This document builds on last year’s statement (you can find it here) and explains the steps We are pleased to share our third modern slavery we are taking at Dr. Martens to prevent, detect and respond to slavery in our business and statement, which gives an update on our previous supply chain. This statement covers Dr. Martens Airwair Group Ltd. and other group companies. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and California achievements and details of further action we Transparency in Supply Chains Act of 2010 (SB 657) and covers the activities between want to take in 2019. October 2017 and January 2019.

KENNY WILSON CEO, Dr. Martens

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT CONTENTS PG3

PG 4 ABOUT US PG 5 OUR SUPPLY CHAIN PG 6 OUR COMMITMENTS AND POLICIES PG 8 OUR FOCUS AREAS PG 10 COLLABORATION PG 11 PROGRESS AT A GLANCE PG 12 WHAT IS NEXT?

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT PG4

WHAT IS ‘MODERN SLAVERY’? HIGHLIGHTS OF 2018: The Ethical Trade Initiative refers to modern slavery as an umbrella term that + Strengthened our policies by introducing a new Migrant Worker Policy and updated includes: , bonded labour, and slavery. The our Supplier Code of Conduct. term “modern” is used to distinguish the complexity of today’s slavery from historical slavery associated with the legal possession of one person by another. + Incorporated human rights and ethical trade into our business Code of Conduct (DOC-trine).

ABOUT US + Conducted compliance audits further Dr. Martens is a footwear brand that was established in Wollaston, UK in 1960, upstream in our supply chain. and has had a manufacturing unit there ever since. Our global head office is + Extended our contractual requirements in Camden, London. with service contractors to include compliance with modern Our products are sold in 243 Dr. Martens branded stores located all around the world, of which 108 of them are owned slavery commitment. by us. We also sell through wholesale and via our website, which ships internationally. In 2018, our group revenue was £348.6m. We employ over 2000 people directly who are based in our stores, + Expanded modern slavery training to offices and warehouses. our key finished goods and raw material suppliers in . Location of employees Stores + Became a signatory of Better Retail Better World to support global efforts UK Head office London 10.79% USA office 5.29% Owned stores 108 to deliver UN SDG 8.7 calling for the UK Factory & Office Wollaston 7.14% USA DC 2.95% Franchises 135 eradication of forced labour and UK DC 2.85% USA Stores 14.84% Concessions 57 modern slavery. EMEA office 0.60% Asia Office 7.29% Pop-Up 11 EMEA & UK Stores 40.76% Asia stores 7.49%

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | ABOUT US OUR SUPPLY CHAIN PG5

WHERE WE PRODUCE AND SOURCE OUR PRODUCTS COMPONENT SUPPLIERS SERVICE CONTRACTORS (1ST TIER SUPPLIERS) (2ND TIER SUPPLIERS) We are a footwear brand, which manufactures and We also work directly with a We also purchase services, sources footwear, clothing and accessories. Our large number of our material consumables and marketing owned and operated footwear factory is located in and component suppliers, materials from various Wollaston, UK. including leather and textiles, contractors. These which are located across include labour agents in We source the majority of our finished footwear, clothing and accessories from factories in China, Thailand, Vietnam, Lao, Portugal and the UK. Asia, Europe and our warehouses, logistic There are more than 25,000 workers in our 1st Tier factories. . operators and not-for-sale product suppliers. Where possible, these suppliers are nominated by us, which allows us to We are in the process of mapping and have better oversight and controls of the assessing the risk of the supply chain of materials used in our products and the our operations in our headquarters and working conditions. regions. While we continue mapping, we have introduced a modern slavery clause in our new agreements. Where contracting on supplier’s terms, we will negotiate compliance with modern slavery commitments.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | OUR SUPPLY CHAIN OUR COMMITMENTS AND POLICIES PG6

SUPPLIER CODE OF CONDUCT ANTI-SLAVERY AND HUMAN TRAFFICKING POLICY EXISTING POLICIES: Our suppliers must adhere to and are audited upon our As stated in our previous + Updated our Supplier Code of Conduct (to include Subcontractor and Supplier Code of Conduct report, to ensure that our own Homeworker Policy) (you can find it here), which employees are aware of their has been in place since 2006. obligations under the Modern + Anti-Slavery and Human Trafficking Policy Slavery Act, we introduced It has been updated annually to reflect best practices. In 2018, we further updated an Anti-Slavery and Human NEW IN 2018: our Supplier Code of Conduct to include Trafficking Policy in 2016. our Subcontractor and Homeworker Policy, Migrant Worker Policy which was originally developed as a stand- alone policy. We also included greater detail We conduct modern slavery awareness training on a regular basis for our relevant Doc-trine (business Code of Conduct) to help suppliers better understand what constitutes modern slavery/forced labour. employees, including those at our sourcing Our Supplier Code of Conduct is based on offices in Asia. Alongside this, we wanted the Ethical Trading Initiative’s Base Code, our employees to have the opportunity and international norms and industry standards. ability to speak up. In 2018, we introduced a confidential hotline as an additional means This year, in addition to sharing our for employees to raise concerns relating policies with all of our first tier suppliers, to human rights, modern slavery, or any we extended this to our key material and other area covered in our business Code of component suppliers, such as tanneries and Conduct (DOC-trine). outsole suppliers.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | OUR COMMITMENTS AND POLICIES PG7

MIGRANT WORKER POLICY THE DOC-trine Migrant workers in supply In addition to updating our Supplier Code of Conduct, we have also introduced a chains are more vulnerable global code of business conduct called The DOC-trine which raises awareness and to modern slavery because expectations amongst our employees regarding human rights and modern slavery. they are unlikely to raise grievances with their employers or the authorities – especially if they are undocumented.

This is a shared concern within the industry and requires a collective and collaborative approach to tackle this issue. This year we introduced a Migrant Worker Policy and implementation guidelines (which you can find here). These are based on the Dhaka Principles, which were developed by the Institute of Human Rights in Business (IHBR) and are based on international best practices, which address the issues migrant workers may face. We introduced these specific policy requirements across SPEAK UP all our key suppliers, focussing first on the suppliers who are based in countries where We have introduced a confidential hotline as an additional means for Dr. Martens employees to raise concerns relating to there is a higher risk of migrant workers. human rights, modern slavery, or any other area covered in our business Code of Conduct.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | OUR COMMITMENTS AND POLICIES OUR FOCUS AREAS PG8

Non-footwear suppliers, which represent around 3% of our total production value, include manufacturers producing our leather and textile accessories, bags 1. SUPPLY CHAIN and garments. RISK ASSESSMENT As a result of our efforts, we have seen: + 1st Tier: Compliance audits extended to non-footwear suppliers. Suppliers in China strengthen their own control mechanisms around recruitment of agency workers + 2nd Tier: Fully mapped component in order to verify employment conditions, as well and material suppliers and extended as to ensure required wages are paid. compliance audits to key component and material suppliers such as tanneries and Suppliers in Thailand are now either employing outsole manufacturers. local staff or directly recruiting migrant workers instead of using recruitment agencies, which has resulted in greater protection of worker rights. 2. CAPACITY BUILDING: Increased transparency from suppliers regarding Modern slavery training to Chinese workers’ wages, supporting the elimination of footwear and key component suppliers as unauthorised monetary deductions. well as our sourcing team who are based SUPPLY CHAIN RISK ASSESSMENT in China. In addition to the compliance audit risk In 2017 we carried out a 2nd Tier material and 3. INTERNAL ENGAGEMENT component supplier mapping survey, covering all our assessments at our 1st Tier suppliers finished good suppliers. Following this work, this year AND AWARENESS BUILDING. explained in the previous report, we mapped all of our 2nd Tier suppliers, including those that are nominated by our suppliers. This has led we have now extended these audits us to consolidate and assess the compliance of these to cover our non-footwear suppliers. suppliers against our standards.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | OUR FOCUS AREAS PG9

SUPPLIER MAPPING STATUS SUPPLY CHAIN CAPACITY BUILDING In 2018, we collaborated with Ethical Trading Initiative (ETI) to provide modern slavery 1st Tier Suppliers 2nd Tier Suppliers Service Contractors training to our key footwear and material suppliers in China. The training provided an opportunity for our key suppliers to engage in the topic and get an overview of what MAPPPING STATUS Fully mapped Fully mapped Partially mapped modern slavery is, the global legislative work around it, and how it links to our Supplier Code of Conduct. During the training, suppliers looked at real examples of modern AUDIT All footwear Partially audited Not yet audited STATUS slavery in China, learning how to identify these risks in their daily operations and what audited, most an acceptable remediation process looks like. Audit against non-footwear Supplier Code of After attending this training, our suppliers committed to further enhance their controls Conduct and Modern audited slavery criteria over their own supply chains as well as providing modern slavery training to their employees. We plan to follow up on these commitments and will continue to provide support to our suppliers on this topic. In 2019, we will extend the modern slavery training to our key suppliers and employees from our other sourcing countries.

Manufacturing INTERNAL ENGAGEMENT AND AWARENESS BUILDING

Tanneries, We continue to raise awareness and suppliers, as it was intended to give a outsole, fabric mills, understanding of modern slavery broader understanding on modern slavery process suppliers, and within other business areas, especially to our team, as well as to underline the other structural materials those directly involved in our sourcing due diligence mechanisms to identify operations and recruitment. As part potential risks in our supply chain. Most of this engagement, we extended our importantly, the training focused on Labour agents, contractors, marketing material suppliers partnership with Ethical Trade Initiative, the impact sourcing practices have on to provide training to our team based a supplier’s ability to operate ethically. in China who manage relationships In the year ahead, we will look for with our suppliers. This was a separate opportunities to extend this training to training session from the one held for other areas of our business. *Audits conducted in 2018/19 at 1st and 2nd Tier: 102

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | OUR FOCUS AREAS COLLABORATION: PG10

We are proud that in 2018 we became We also joined, along with other major a signatory of the British Retail UK retailers’, a CEO forum on modern Consortiums industry initiative, slavery, organised by ASOS, one of our Better Retail Better World. key customers. This is a voluntary scheme, which aims to mobilise the The aim was to identify and address the risks of forced retail industry to tackle some of the biggest global labour and human trafficking in collective supply chains challenges of the coming decades, highlighted by the UN Discussion points included the modern slavery challenges, Sustainable Development Goals. These include respecting risks companies face and ideas for addressing them. human rights, supporting sustainable markets and All participants agreed to greater transparency, improved developing skills, which are fundamental to businesses. reporting, increased collaboration and training for different stakeholders.

HERE AT DR. MARTENS, WE ARE COMMITTEDcommitted TO ERADICATING FORCED LABOUR AND MODERN SLAVERY BY WORKING WITH OTHERS AND PROMOTING GOOD PRACTICES IN OUR OWN OPERATIONS AND SUPPLY CHAIN.

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | COLLABORATION PROGRESS AT A GLANCE PG11

As a business, we are committed to the continuous improvement in our approach to tackle modern slavery, forced labour and human trafficking. We have achieved good progress against the commitments we set last year. Here is a summary of what we have accomplished so far:

2017/18 COMMITMENT We are creating a structure to Developing a Migrant Worker Extend our CSR assessments enable our regional sales and stores Modern slavery training We are increasing our Policy that will cover principles in all non-footwear factories teams to recognise modern slavery will be provided at all resources in Asia to start and requirements to guide our to get a better understanding risks in their own operations. This our finished product assessing our second tier internal teams and suppliers of the labour standards and includes services, consumables, suppliers and our own suppliers to understand the towards best practices when working conditions. and the marketing materials they regional offices. conditions in those factories. employing migrant workers. receive from contractors.

2018/19 PROGRESS CSR audits extended in Updated our requirements for Partnered with ETI to Working with internal teams to map We have recruited an Asia CSR non-footwear suppliers in Asia, Gift with Purchase suppliers conduct modern slavery our service, marketing materials and officer who is responsible for as well as European suppliers to incorporate ethical trading training to key suppliers consumables contractors, starting assessing 2nd Tier suppliers including UK. standards, including their own in China. with those in the UK, followed by and supporting our 1st statement on modern slavery. those in Asia and the Americas. Tier suppliers.

Migrant Worker Policy and implementation guidelines are developed and shared with all finished good suppliers and key raw material suppliers. MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | PROGRESS AT A GLANCE WHAT IS NEXT? PG12

NEXT YEAR, WE WILL: + Continue the previous years objectives. Further map the risks deeper in our supply chain and operations.

+ Provide more training to our own employees and our suppliers in sourcing countries beyond China.

+ Tackle the root causes of modern slavery by implementing responsible recruitment best practices and using more in-depth/ stringent assessment techniques during the audits.

+ Identify and partner with key external stakeholders and seek further collaboration with other industry members and NGOs.

Additional information can be found on the social responsibility section of our website: www.drmartens.com/uk/social-responsibility This statement was approved by the Board of Directors of Dr Martens AirWair Group Limited. KENNY WILSON CEO, Dr. Martens

MODERN SLAVERY AND TRANSPARENCY IN THE SUPPLY CHAIN STATEMENT | WHAT IS NEXT?